- 5 - verification of reasonable cause for abatement of additions to tax and that respondent would assume that there was none unless such was provided within the next 15 days; (2) that consideration of petitioner’s bankruptcy assertion must be made in the light of the new bankruptcy laws which take “a harder look at future income than the old law did”. The settlement officer noted that “You have significant income potential, as you have displayed through past performance, and I do not think that you would avoid paying all the taxes if you file [for bankruptcy]”; and (3) that if petitioner wished to enter into an installment agreement, he should, through his representatives, contact respondent within 15 days. Petitioner responded to the settlement officer’s December 22, 2005, letter by reiterating his position that respondent had not given adequate consideration to his potential bankruptcy because respondent had not considered that his future earnings were uncertain because petitioner was aging and was at that time practicing law without associates and without a formal office or support staff. In addition, petitioner contested the settlement officer’s calculation of petitioner’s realizable collection potential, claiming that increased allowances should have been made for petitioner’s basic living expenses. Petitioner did not attempt to enter into an installment agreement and did not respond to the invitation to submit verification of reasonablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007